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1 Introduction

A Management Responsibilities Map supports the individual Statements of Responsibility (SoR) but is only required by enhanced firms. It provides an overview of how a firm is managed and governed and offers guidance and support for internal and external individuals on understanding the firms structure, reporting lines and who has been allocated which responsibilities.

[Your Company Name] (hereinafter referred to as the “Company”) have developed a structured, but easy to follow map that denotes all employees holding one or more SMF’s and details their position, prescribed responsibilities, overall responsibilities and reporting lines. The map also includes organisational structure charts and a summary of any relevant boards and/or committees.

Our management responsibilities map is made readily available to all relevant employees and has been designed to help the FCA identify who it needs to speak to about particular issues and which responsibilities they have oversight for.

[You should use your SoR template provided by the FCA and available in your pack to complete this document and should keep completed SoR’s with this document for supporting information.]

2 Objectives & Obligations

The FCA have set out several rules and requirements for the purpose and content of the Management Responsibilities Map in SYSC 25 of the handbook. These inclusions are set out below and the Company have ensured that our map template contains all the required details and information.

The Company will ensure that it: –

  • keeps a comprehensive and up-to-date document for (either hardcopy or electronic) that accurately describes our management and governance arrangements
  • as an overseas SMCR firm, we will ensure that the above noted document is maintained for any branch we maintain in the United Kingdom [delete if not applicable]
  • retains a management responsibilities map that includes: –
    • details of the reporting lines and the lines of responsibility
    • the names of all the Company’s:
      • approved persons (including PRA approved persons)
      • members of its governing body and (if different) management body who are not approved persons
      • senior management
      • senior personnel
    • details of the responsibilities which they hold
  • all responsibilities described in any current statement of responsibilities
  • details of the management and governance arrangements relating to:
    • the FCA and/or PRA-prescribed senior management responsibilities and who those responsibilities are allocated to
  • details and reasons for allocating any FCA and/or PRA-prescribed senior management responsibilities to more than one person jointly or have divided the responsibility between different persons (if applicable)
  • details about the functions allocated under, SYSC 26, including:
    • what the activities, business areas and management functions allocated under that chapter are
    • the management and governance arrangements relating to them
    • the identity of the persons to whom those functions are allocated
  • matters reserved to the governing body (including the terms of reference of its committees) and, if different, the management body
  • details of how the Company’s management and governance arrangements fit together with its group and any other person and the extent to which those arrangements are provided by, and shared with, other members of its group or others
  • details of the reporting lines and the lines of responsibility between the firm and those who carry out functions in relation to it and other members of its group or other third parties; persons acting as employees or officers of, or otherwise acting for, anyone in; or committees or other bodies
  • reasonable information about the persons described or identified in the management responsibilities map, including:
    • whether they are employees of the Company and, if not, by whom they are employed
    • if they are certification employees of the firm
    • the responsibilities they have in relation to other group members or any other person
  • details of how all the above information and relationships fit together and fit into the Company’s management and governance arrangements as a whole

3 Group Structure

[DELETE IF NOT APPLICABLE: Insert flowchart for the structure of any group(s) and provide a summary of how the group governance works and context for the structure of the group. NOTE: It is not mandatory to include information about the group structure, but it may help to provide context.]

4 Governance Structure

[Insert flowchart for any boards & committees to show the structure and those who are members.]

4.1 Boards & Committees Summary

TYPE SMF MEMBERS OTHER MEMBERS MEETING FREQUENCY PURPOSE & DESCRIPTION
(i.e.) Board John Jones – SMF3 Jane Smith Monthly The board is the governing body of the firm and aids in the long-term success of the firm
(i.e.) Renumeration Committee Sally Dixon – SMF13 Jason Dolly Weekly The Renumeration Committee sets the policies and procedures for renumeration and audits processes in this area

5 Management Structure

[Insert organisation chart for the structure of the firm showing the management structure. NOTE: You should add the name and position of each individual into the charts in a flowchart format which depicts management structure and reporting lines. (For chart examples, see the FCA’s GC18/4 map examples).]

5.1 Reporting Lines & Lines of Responsibility

[Insert organisation charts for the reporting lines of the firm and between those identified on this map. It is not mandatory to provide the reporting lines in a flowchart format (i.e. you can use a table if preferred), however whatever format you choose should enable those reviewing the map to clearly see who reports to who and what lines of responsibility run through the corporate structure.]

5.2 Senior Management Function Allocations

SYSC 25 requires that all Senior Management Functions (SMF) are allocated to an individual and documented in the Statement of Responsibilities (SoR) and or enhanced firms, on the responsibilities map. Where a SMF applies to the Company, the person to whom the function has been allocated and their position are detailed below.

Note: This table includes all Senior Management Functions (SMF), including who they have been allocated to and what position that individual holds.
REF SENIOR MANAGEMENT FUNCTION ALLOCATED TO POSITION
SMF1 Executive function
SMF2 Chief Finance function
SMF3 Executive Director
SMF4 Chief Risk function
SMF5 Head of Internal Audit
SMF6 Head of Key Business Area
SMF7 Group Entity Senior Manager
SMF8 Credit Union SMF
SMF9 Chairman
SMF10 Chair of the Risk Committee
SMF11 Chair of the Audit Committee
SMF12 Chair of the Remuneration Committee
SMF13 Chair of the Nominations Committee
SMF14 Senior Independent Director
SMF16 Compliance Oversight
SMF17 Money Laundering Reporting
SMF18 Other Overall Responsibility function

[If an SMF is not allocated, provide a reason why to demonstrate you have not missed allocating any functions. Include other SMF’s if they apply to your firm (i.e. SMF21-24)]

5.3 Prescribed Responsibilities

This section of the map details what prescribed responsibilities apply to the firm and who each responsibility has been allocated to. It also indicates if the prescribed responsibility has been shared or divided between two people and if so, what the reason for this split is. Additional information about the allocated responsibilities have been provided in the individual Statement of Responsibilities (SoR).

PRESCRIBED RESPONSIBILITIES ALLOCATED
REF DESCRIPTION OF PRESCRIBED RESPONSIBILITY (PR) ALLOCATED TO POSITION IS PR SHARED OR DIVIDED?
a Responsibility for the firm’s performance of its obligations under the senior management regime YES/NO
aa Responsibility for the management of the firm’s risk management policies and processes YES/NO
b Responsibility for the firm’s performance of its obligations under the employee certification regime YES/NO
b-1 Responsibility for the firm’s obligations for:

(a)    Conduct rules training and;

(b)   Conduct rules reporting

 YES/NO
bb Responsibility for managing the systems and controls of the firm
c Responsibility for compliance with the requirements of the regulatory system about the management responsibilities map YES/NO
cc Responsibility for managing the firm’s financial resources
d Overall responsibility for the firm’s policies and procedures for countering the risk that the firm might be used to further financial crime YES/NO
dd Responsibility for ensuring the governing body is informed of its legal and regulatory obligations
ee Responsibility for the escalation of correspondence from the PRA, FCA and other regulators in respect of the firm to each of the governing body or the management body of the firm and, as appropriate, of the firm’s parent undertaking and the ultimate parent undertaking of the firm’s group YES/NO
f Responsibility for:

(a)    leading the development of; and

(b)   monitoring the effective implementation of; policies and procedures for the induction, training and professional development of all members of the firm’s governing body

 YES/NO
ff Responsibility for the firm’s compliance with the UK regulatory system applicable to the firm YES/NO
g Responsibility for monitoring the effective implementation of policies and procedures for the induction, training and professional development of all firm’s:

(a)    SMF Managers and;

(b)   Key function holders (other than members of the firm’s governing body)

 YES/NO
j Responsibility for:

(a)    safeguarding the independence of; and

(b)   oversight of the performance of the internal audit function in accordance with internal audit requirements for SMCR firms

 YES/NO
j-2 Responsibility for:

(a)    providing an effective internal audit function in accordance with one of the relevant sections in the PRA Handbook

(b)   overseeing the performance of the internal audit function

 YES/NO
k Responsibility for:

(c)    safeguarding the independence of; and

(d)   oversight of the performance of; the compliance requirements for SMCR firms

 YES/NO
l Responsibility for:

(a)    safeguarding the independence of; and

(b)   oversight of the performance of; the risk function in accordance with the risk control requirements for SMCR firms

 YES/NO
m Responsibility for overseeing the development of, and implementation of the firm’s remuneration policies and practices in accordance with SYSC 19D YES/NO
n Acting as the firm’s whistleblower’s champion YES/NO
o Management of the allocation and maintenance of capital, funding and liquidity YES/NO
p The firm’s treasury management functions YES/NO
q The production and integrity of the firm’s financial information and its regulatory reporting in respect of its regulated activities YES/NO
r The firm’s recovery plan and resolution pack and overseeing the internal processes regarding their governance YES/NO
s Responsibility for managing the firm’s internal stress-tests and ensuring the accuracy and timeliness of information provided to the PRA and other regulatory bodies for the purposes of stress-testing YES/NO
t Responsibility for the development and maintenance of the firm’s business model by the governing body YES/NO
u Responsibility for the firm’s performance of its obligations under Fitness and Propriety (in the PRA Rulebook) in respect of its notified non-executive directors YES/NO
v If the firm carries out proprietary trading, responsibility for the firm’s proprietary trading activities YES/NO
w If the firm does not have an individual performing the Chief Risk function, overseeing and demonstrating that the risk management policies and procedures which the firm has adopted in accordance with SYSC 7.1.2 R to SYSC 7.1.5 R satisfy the requirements of those rules and are consistently effective in accordance with SYSC 4.1.1R. YES/NO
x If the firm outsources its internal audit function taking reasonable steps to ensure that every person involved in the performance of the service is independent from the persons who perform external audit, including:

(a)    Supervision and management of the work of outsourced internal auditors and

(b)   Management of potential conflicts of interest between the provision of external audit and internal audit services

 YES/NO
y If the firm is a ring-fenced body, responsibility for ensuring that those aspects of the firm’s affairs for which a person is responsible for managing are in compliance with the ring-fencing requirements. YES/NO
z Responsibility for the firm’s compliance with CASS YES/NO

[This table includes the list of PRs’ provided in SYSC 24.2.6 and as detailed in the SoR template. You should provide a supporting note for any PR that is shared or divided, noting the reasons and indicate where a PR is not applicable so that it is clear you have not missed allocating any responsibility.]

5.4 Overall Responsibilities

This section of the map details what overall responsibilities have been allocated to each individual and where applicable, if that responsibility has been shared or divided between two people and if so, what the reason for this split is. Additional information about the overall responsibilities have been provided in the individual Statement of Responsibilities (SoR). Overall responsibilities ensure that an SMF manager is responsible and accountable for every area of a firm’s activities; business areas and management functions.

OVERALL RESPONSIBILITIES ALLOCATED
REF TITLE OF OVERALL RESPONSIBILITY (OR) DESCRIPTION OF OVERALL RESPONSIBILITY ALLOCATED TO POSITION IS OR SHARED OR DIVIDED?
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
 
  YES/NO

[You should systematically go through all the firm’s activities; business areas and management functions and ensure that they have been allocated to a Senior Manager who is responsible and accountable for that area or function.]

5.5 Details of Individuals Included in Responsibilities Map

SYSC 25.2.3 requires that in addition to detailing who has been allocated the relevant Senior Management Functions, Prescribed Responsibilities and Overall Responsibilities, those included on the Responsibilities Map must be identified and their reporting lines and employment status confirmed. Below are all individuals that the firm has identified in this map with their supporting details.

Note: This table includes all individuals identified on the responsibilities map and provides reasonable details about each of them.
NAME POSITION REPORTS TO EMPLOYEMENT STATUS CERTIFICATION EMPLOYEE? BOARD/COMMITTEE APPOINTMENTS
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO
  YES/NO

6 Matters Reserved for the Board

[SYSC 25.2.3(6) requires that the responsibilities map details matters reserved to the governing body (including the terms of reference of its committees) and, if different, the management body. You should add any relevant information here.]